Taxi and Private Hire Car Market and Local Licensing Regimes

TAXI AND PRIVATE HIRE CAR MARKET AND LOCAL LICENSING REGIMES

James M Cooper, Taxi Research, Edinburgh Napier University

Table of Contents

1 EXECUTIVE SUMMARY 1

Approach 2 Primary findings 2

2 BACKGROUND 5

3 QUANTITATIVE RESPONSES 7

Driver and vehicle licence policies 7 Accessibility and vehicle type policies 8 Training policies 11 Taxi Tariffs 11

4 POLICY DETAIL 12

Qualitative responses – licence restriction 12 Qualitative responses - accessibility 12 Training 14 Trade structure and representation 15 Issuing, refusing and withdrawing licences 17

5 REVIEW 20

Licensing policies and policy engagement 22 Training for taxi Drivers 23 Licence transferability 25

6 CONCLUSIONS 25

7 APPENDICES 27

Appendix 1: Survey Document 27 Appendix 2: Survey Responses 32

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1 EXECUTIVE SUMMARY 1.1 The Taxi Studies Group based at the Transport Research Institute, Edinburgh

Napier University (TRI) has undertaken a review of the Taxi and Private Hire Car (PHC) market in Scotland, on behalf of the Justice Directorate of the Scottish Government. The work identifies policy approaches adopted by local licensing authorities, including differences in approach between authorities, and key common approaches including those to vehicles permitted within taxi and PHC fleets, the extent and nature of training required, and the administrative processes by which taxis, PHCs and their drivers are licensed across Scotland.

1.2 Taxi and PHC services are licensed, in Scotland, pursuant to the Civic Government (Scotland) Act 1982, which defines the nature of licensing, controls and market tests required at a local level. The issuing of licences and determination of local policies falls to local authorities, Licensing Authorities, at a city and district level. Each of the 32 Scottish Local Authorities is responsible for issuing licences within their geographical boundaries, as well as the determination of vehicle requirements in terms of age limitation, numbers of taxi licences that may be issued1, and maximum fares2. In some authority areas, historic boundaries and/or splits between urban and rural populations, have led to the presence of differing taxi zones, though this is represented in a minority of authorities. A current example is the issuing of differing “airport plates” by Aberdeen City Council.

1.3 The Taxi and Private Hire Car market is broadly categorised by two differing market operations, the taxi fleet, which is able to “ply for hire”, pick up on street and at taxi stances, as well as responding to pre-booked trips; and the PHC market which is able to pick up in response to pre-booked trips only3. A requirement may also be placed on vehicle type, most commonly the use of Wheelchair Accessible Vehicles (WAV4), which can be required of the taxi market. No Scottish Licensing Authority currently places the same requirement on PHCs.

1 The Civic Government (Scotland) 1982 Act allows for a limitation to be applied to the taxi fleet, but not to PHC fleets. Best practice guidance exists (Scotland, 2007; 2011) in relation to the regulation of local markets. 2 Taxi fares are determined on the basis of a taxi tariff, sometimes called a meter rate, defined for each authority area. 3 A variety of terms are applied across the UK and internationally to the market segments described, as well as the methods of engagement, for example, taxis currently defined as Hackney Carriages in England and Wales, and Private Hire Cars (PHCs), defined as Private Hire Vehicles (PHV). Other differences include the term Taxi stance (Taxi Rank / Cabstand) giving rise to the term “ranking market”, and street pick up (Street Hail) giving rise to the term “Hailed” or “Hailing” market. 4 Also known as Wheelchair Accessible Taxis (WAT)

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Approach

1.4 Primary research was undertaken in the Summer of 2012, and focused on a survey of Licensing practices sent to all 32 licensing authorities in Scotland, set out in appendix 1 of this document. Questions split between the Licensing process, being the methods by which drivers and operators were issued licences, and the nature of official involvement, including that of the Police. Additional questions were included to determine the process by which licences may be suspended or revoked. The survey also sought to identify the structure of the taxi and PHC industry in each location.

1.5 A further section also sought to identify the nature of training provided in each location. A series of areas in which training and awareness would be appropriate was identified, and further split between taxis and PHCs. Subsequent questions identified local approaches to the transfer ability of licences and the methods by which licensing authorities recognised and took account of local views and identified trends in their local market.

Primary findings

1.6 A total of 19 valid responses were received, though not all the respondents chose to answer all the questions included in the survey. All the authorities which responded identified that they licensed taxi and PHC fleets separately, with 85% of respondents also licensing both driver and vehicle separately. Authorities can license both drivers and vehicles, though there are neither common time patterns nor legislated timescale for either. The typical validity of a licence ranged between one and three years, with a relatively even split between new licence validity, the majority being valid for one year and renewals, the majority being valid for 3 years.

1.7 Licensing processes also followed a common pattern; the majority of authorities requiring the same underlying checks to both driver and vehicle licensing. These included a police check, criminal records checks, and vehicle standards. A minority also wished drivers to undertake occupational health checks. Applicants would be refused a licence if they were demonstrated not to be “fit and proper”, a defined requirement included in the Civic Government (Scotland) Act. A number of authorities set out the process by which police objections would be considered a ground for refusal.

1.8 Vehicle standards also appeared to be of significance, with 38% of all respondents reporting a defined accessibility policy, typically a requirement for

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WAVs to be included in the taxi fleet. None of the respondents reported a requirement for PHCs to be fully accessible, though one identified a WAV requirement for larger PHC vehicles. Some responses identified a need for a national policy, as no defined standards are currently in place as to what constitutes a Wheelchair Accessible Vehicle, the precise definition falling to the Licensing authority with quite significant differences in vehicles accepted as WAV compliant. Two authorities reported that their own approach was to await national guidance from the Scottish Government before setting a local policy.

1.9 Differences existed between authorities requiring 100% of their taxi fleet to be accessible, and those choosing to require a proportion of their fleet to be operated by WAV. Authorities without accessibility policies typically allowed the use of four-door saloons and five door hatchbacks, with a smaller number of authorities permitting smaller vehicles.

1.10 The survey addressed the choice of an authority whether to restrict licence numbers, known variously as a closed market, a licence cap or a restricted entry market. 44% of respondents indicated they operated a policy of licence restriction, most commonly in cities. The most common reason for not limiting licence numbers related to the fact that overall numbers of taxis and PHCs were too small to require a cap, whilst those with a cap highlighted that their analysis [required by the Civic Government (Scotland) Act 1982] did not indicate unmet demand.

1.11 The survey also addressed the need for training, identifying six areas of knowledge that might be desirable. This included: geographical knowledge, customer care, equality and diversity, disability awareness, awareness of licensing requirements, and safety training. Licensing awareness and safety training were the greatest response, with a small bias towards requiring training in the taxi fleet, as opposed to PHC fleet. The smallest response was for equality and diversity training, required by less than 10% of all respondents. Disability awareness was required by a relatively small number of authorities, and fewer authorities required this training than required WAV inclusion in their fleet, which suggested that some authorities with WAV requirements did not extend the need for accessible carriage to training.

1.12 Questions relating to the transferability of licences were also included in the survey. Authorities identified that the direct transfer of licences was not permitted under the meanings of the Civic Government (Scotland) Act, though some identified that demand for transfers existed, outlining some of the methods by which such a transfer might occur. Where the transfer of licences occurred, this appeared most commonly related to corporate takeovers, and the ownership of taxi operating companies. A desire for clarity related to the

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transferability of licences was expressed by a number of authorities, particularly in terms of the change in corporate ownership of taxi operating companies, with acknowledgement of the impacts on operator and driver expectations that market values and existence of licence transferability might have.

1.13 Significant differences existed between authorities in relation to the method by which public and industry views were sought and considered, ranging between regular forum and occasional ad-hoc postal engagement, though all authorities identified a need to be aware of and consider the range of impacts that may arise from policy development. The range of stakeholders and methods of engagement are set out in subsequent text, whilst the frequency of such engagement was considered to relate to the requirements for policy development and extent to which engagement would be taken up.

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2 BACKGROUND 2.1 The Taxi Studies Group based at the Transport Research Institute, Edinburgh

Napier University (TRI) has been asked by the Justice Directorate of the Scottish Government to undertake a review of local licensing regimes across Scotland, set out in this report. The work seeks to identify current practices across Scottish licensing authorities, together with an overview of the context in which such practices occur, based on a survey of licensing authorities. We have arranged our report to provide an overview of taxi policy, a review of the most common forms of Licensing applied to the sector, and the responses to our survey. In this section we have set out service definitions and licensing approaches reported on in subsequent parts of our report.

2.2 The Taxi and Private Hire Car market broadly falls into two categories: taxis, which are able to pick up on street, at stance (taxi rank) and respond to telephone bookings (pre-booked trips); and Private Hire Cars (PHC) which are limited to pre-booked trips only. The taxi, referred to as a Hackney Carriage in England and Wales and as a Public Hire Taxi in Northern Ireland, can have additional limitations applied, including a requirement for the use of wheelchair accessible vehicles (WAV), and may also be limited to a defined number5. In contrast, Private Hire Cars6 may not be restricted in number. Additional vehicle types, including taxibuses, are less common in Scotland, as set out in subsequent sections, but are permitted under current legislation.

2.3 Local government responsibility for taxis and PHCs in Scotland falls to the 32 licensing authorities, each responsible for applying current legislation to their taxi fleets and Taxi Booking Offices. Controls can be applied to the licensing of vehicles, their drivers, and in ensuring vehicle standards and enforcing fares where defined, and the licensing of premises used for the taking of bookings for taxis and private hire cars7. Fares are typically defined through the use of a Taxi Tariff, a defined rate for distance, time and stated extras, though the actual content and make up of the tariff can vary significantly between authorities. The summation of the elements defined in the tariff results in a taxi fare, which is likely to be unique to the time and circumstance of each journey being made.

5 At the time of writing, a limit to the number of taxi licences issued in an authority area may be pursued under the terms of the Civic Government (Scotland) Act 1982, where such a limit is demonstrable as being in the public interest 6 Equivalent terms: Private Hire Vehicles – PHV (England and Wales), Private Hire Taxis (Northern Ireland). 7 The Civic Government (Scotland) Act 1982 (Licensing of Booking Offices) Order 2009

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2.4 Current figures (Transport Scotland, 20118) suggest an overall taxi parc of 10,500 Licensed taxis9, with 25,500 taxi drivers; and 10,700 PHCs, with 11,250 PHC drivers. The figures suggest that each taxi may be driven by an average of more than two drivers; whilst PHCs are far more likely to have a single driver. This reflects, in part, the differences in operating patterns of the two vehicle types, and the higher number of taxis in urban and city environments, and is set out in more detail in subsequent sections.

2.5 Of the taxi fleet, a limited proportion is comprised of Wheelchair Accessible Vehicles (WAVs) - vehicles that have been purpose built or adapted to accommodate wheelchairs. The 2011 statistics suggest 4,900 WAV taxis are available across Scotland, though these are most commonly available in larger cities in which a specific WAV requirement is defined. Of the 10,700 PHCs, only 260 were accessible in 2011. There are some differences in the definitions of vehicle types appropriate for use as WAVs, and policies toward training for their use, described in subsequent sections.

2.6 Some changes are noted in the number of vehicles available when comparing the Scottish Transport Statistics with responses to our survey, often reflecting updates to the numbers of taxi licences issued in some authority areas, but also reflecting changes to policies on WAVs. These are set out in detail in the body of this report.

2.7 The TRI study, described in subsequent sections, is based on a comprehensive survey of Scottish licensing authorities. Questionnaires were sent to all 32 licensing authorities, with 19 detailed responses received. Survey work was undertaken in Autumn 2012, with follow up and analysis completed in November. In section 3 we set out responses and quantitative analysis, including licensing policies and authority types. In section 4 we include qualitative information and define contexts that influence policy decisions, with a concluding section, Section 6, highlighting common approaches to the licensing and control of taxis, and issues arising between locations.

8 Scottish transport statistics number 30:2011 edition, table 1.4, taxi, private hire cars and drivers licensed by local authority area, 2011 9 The taxi “parc”, as opposed to “fleet” refers to the numbers of vehicles available for use at any one time

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3 QUANTITATIVE RESPONSES Driver and Vehicle licence policies

3.1 All authorities responding to the survey distinguish between taxis and PHCs

with 100% of respondents licensing the two fleets separately. 85% of respondents also licensing both driver and vehicle separately.

3.2 Authorities can license both drivers and vehicles, though there are neither common patterns nor legislated timescale for either. Typical validity ranged from 1 – 3 years, with a relatively even split between new licence validity of one year (47% of respondents), two years (12%), and three years (35%). Driver licences were more likely to last three years on renewal (50%), with 37.5% lasting one year. The same two authorities issuing new licences for two years also renewed licences for two years (Renfrewshire and Glasgow).

3.3 An authority has a choice between open and restricted markets, an open market being one in which a potential operator meeting the minimum operating criteria set by the authority, may obtain a licence. The alternative, a restricted market, defines a maximum number of licences that may be issued at any one time, refusing new applications once this limit is reached10. Of the respondents, just under half (44%) indicated that they maintained a policy of licence restriction, of which over half indicated that their own analysis of unmet demand had indicated that no Significant Unmet Demand (SUD) had been identified. The actual numbers of vehicles operating under restriction was higher (72%), however, than those operating in an open market (28%) suggesting that more populous authorities were more inclined to operate a policy of licence restriction, than more rural ones. This was borne out in commentary from authorities that did not apply restriction, that the number of taxis and PHCs were too small to justify restriction. One authority, Dumfries and Galloway, indicated a split between its policy applied in Dumfries, where numbers were restricted, and that applied in the other (more rural) parts of the authority area, where numbers were not restricted.

3.4 The extent of information and processes undertaken for licensing authorities differs slightly between authorities, with the majority requiring the same underlying checks for both Driver and Vehicle licensing. 80% of all respondents indicated that a driver would require a police check, although the method of checking differed between locations, ranging from a pro-active Scottish Criminal Records Online (SCRO) check, to a passive issue if no

10 “Restricted Markets” in Scotland are not truly closed insofar as any restriction is dynamic, can be varied, in response to a survey consistent with the Civic Government (Scotland) Act 1982, and Best Practice Guidance(s) issued in the period since the 1982 Act.

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adverse comments were made, as set out in detail in subsequent sections. A smaller number (7%) also required an occupational health check. The majority of authorities underlining that an applicant would be refused a licence if they were not demonstrated to be a “fit and proper person”.

3.5 Vehicle licensing typically required vehicle inspection, varying between an MOT presentation (54%) and an additional mechanical test (20%), undertaken by the licensing authority’s testing agent, which includes the Lothian and Borders Police Taxi Examination Centre in Edinburgh; and the licensing authority inspection centres in Glasgow and Aberdeen.

3.6 All authorities (100%) stated that they would refuse a licence application in accordance with the Grounds for Refusal set out in the Civic Government (Scotland) Act 1982. Most also stated that the principal ground for refusal related to the “Fit and Proper Person” requirement as laid out in the Act. 40% of respondents highlighted that refusal would follow an objection from the police to the issuing of a licence. A small number (14%) indicated that an applicant facing a licence refusal would have the right of a licensing panel hearing. taxi licence applications, as opposed to those for PHC licences, could also be refused on the grounds of availability, when the defined number of licences had been reached.

3.7 A number of authorities illustrated grounds for the suspension of licences, including the failure to provide required equipment in the vehicle, as set out in more detail in section 4.

Accessibility and vehicle type policies

3.8 The survey sought to identify the extent to which common policies were applied in relation to accessibility, with subsequent sections identifying the range of training available and required. 38% of all respondents had a defined policy requiring WAVs to be included in the fleet. Large cities tended to have a more defined policy toward WAVs than other locations, with Edinburgh, Glasgow and Aberdeen all reporting an accessible requirement. It is noted that these cities are all licensed by an urban council. In other city locations, such as Inverness, the licensing authority also has responsibility for large rural areas. The Highland Council, in the case of Inverness, does not apply a WAV requirement of its fleet. Urban peripheral communities were also more likely to apply a WAV requirement (see figure 1).

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Figure 1: Licensing Authorities with WAV requirements

3.9 The exact definitions of WAVs and the policy toward their use differed slightly,

with both Edinburgh and Glasgow requiring 100% of their taxi fleet to be comprised of purpose built WAVs. Aberdeen had also defined an accessible requirement that all new taxis needed to be accessible, with all of the city fleet to be accessible by 2017.

3.10 Permitted vehicle types differed between locations (see chart 1), with a significant majority of authorities permitting the use of 5- and 6-seater WAVs. A number (60%) also permitted the use of larger van type vehicles.

3.11 Authorities without an accessibility policy typically allowed the use of 4-door saloons and 5-door hatchbacks. A small number (17%) permitted the use of small hatchback vehicles, and a limited number (25%) also allowed the use of 2-door saloons in their fleet.

1. Aberdeen city council 2. Aberdeenshire 3. Angus 4. Argyll & Bute 5. Clackmannanshire 6. Dumfries & Galloway 7. Dundee city 8. East Ayrshire 9. East Lothian 10. East Renfrewshire 11. Edinburgh, city of 12. Eilean Siar 13. Falkirk 14. Fife 15. Glasgow city 16. Highland 17. Inverclyde 18. Midlothian 19. Moray 20. North Ayrshire 21. North Lanarkshire 22. Orkney Islands 23. Perth & Kinross 24. Renfrewshire 25. Scottish borders 26. Shetland Islands 27. South Ayrshire 28. South Lanarkshire 29. Stirling 30. West Dunbartonshire 31. West Lothian

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Chart 1: Permitted vehicles in the taxi fleet

3.12 A more even spread was identified in vehicles permitted to operate as PHCs

(see chart 2). No authority placed a requirement on accessibility for PHCs, though all permitted some form of accessible vehicles to operate in their fleet. The vast majority (83%) stated that 5-door hatchback vehicles would be permitted, with a majority (between 65% and 75%) permitting differing saloon and accessible vehicles. A small number permitted 2- and 3-door vehicles (17% and 25% respectively).

Chart 2: Permitted vehicles in the PHC fleet

0.00%10.00%20.00%30.00%40.00%50.00%60.00%70.00%80.00%90.00%

0.00%10.00%20.00%30.00%40.00%50.00%60.00%70.00%80.00%90.00%

100.00%

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Training policies

3.13 A number of authorities placed additional training requirements on their taxi and PHC fleets, summarised in chart 3. Training can range from a local geographical knowledge, required of taxis in 41% of responding authorities, and customer care required of taxis in 25% of responding authorities.

Chart 3: Required training, taxis and PHCs

3.14 Awareness of licensing conditions and safety were most often seen as

appropriate for both taxi and PHC fleets, with the least common form of training specific to Equality and Diversity. A higher level of training was generally required for taxi drivers than for PHC drivers, with the most significant difference noted for Geographical Knowledge, required of 41% of taxi drivers, and only 17% of PHC fleet drivers.

Taxi Tariffs

3.15 A further difference between taxi and PHC fleets related to the setting of taxi

tariffs (fares), and use of meters. In the majority of licensing authorities, taxis were required to be fitted with a meter (100%) whilst PHCs did not. Two authorities, Aberdeen City Council and Aberdeenshire, reported that PHCs were also required to be fitted with a taximeter, with both authorities requiring PHCs to follow the same fare structure as applied to their taxi fleets.

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

TAXI

PHC

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3.16 A further question was posed in terms of the transferability of taxi and PHC licenses. All but one authority indicated that taxi licences were not transferable, although four acknowledged that the practice did take place. Two identified specific problems arising in relation to the transfer of licences, discussed in more detail in subsequent sections.

4 POLICY DETAIL Qualitative Responses – Licence Restriction

4.1 Licence restriction relates to the choice to limit the numbers of licences issued. An authority may restrict the numbers of taxi licences, but not those of PHCs. An authority choosing to restrict taxi licence numbers must undertake a review to satisfy itself that the restriction is in the public interest and that no unmet demand results from the restriction (Civic Government (Scotland) Act 1982). This is most often undertaken as a test of Significant Unmet Demand (SUD), with a number of Best Practice Guidance documents produced in Scotland and by the UK Department for Transport.

4.2 44% of responding authorities indicated that they currently applied restrictions, with a larger number of taxis operating in a restricted location than in a location without restrictions, ie: more populous authorities are more likely to apply restriction. City respondents all commented on recent SUD surveys indicating that a policy of restriction had not resulted in Significant Unmet Demand. A number also indicated they had not received representations suggesting an increase would be appropriate.

4.3 A number of rural authorities indicated that they did not license sufficient numbers of taxis to justify the application of a policy of restraint.

Qualitative Responses - Accessibility

4.4 In addition to a quantitative review, the study identified the context in which policies were applied, the local circumstances that impacted on the regulations and their interpretation, and the potential benefits to passengers.

4.5 Accessibility was highlighted in a number of responses, and is seen as a significant issue in allowing use of taxis across differing user types. Key to this is the provision of vehicles appropriate to the needs of the travelling public. A variety of vehicle types are available and permitted across Scottish licensing authorities (see sections 3.7 and 3.8), most commonly split between Saloon type vehicles and Wheelchair Accessible Vehicles (WAVs). Smaller saloon

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type vehicles are less common and are permitted in a few authority areas. Larger types of saloons including Hatchbacks are in common use in the PHC fleets across Scotland, and a number of taxi fleets.

4.6 38% of respondent authorities applied a WAV requirement for taxis, though none required the same of their PHC fleets. WAVs are typically designed to allow access for a wheelchair to the vehicle, allowing the passenger to remain in their wheelchair throughout the journey. A wheelchair user travelling in a wheelchair would not need to dismount, nor fold their chair. It is noted that some literature highlights a difference between the accessibility of WAVs to wheelchair users and users with other forms of disability.

4.7 A variety of differing vehicle makes and models can be defined as wheelchair accessible, with a common distinction made between side-loading vehicles, those allowing wheelchairs to gain access from the pavement through a side door, and rear loading, those requiring access from the street through a modified boot. The difference in entrance has a bearing on the position of the wheelchair user, either facing towards or away from the direction of travel, with many side entry WAVs requiring a wheelchair to be secured with the passenger’s back to the direction of travel, although this does not apply to all side entry vehicle designs.

4.8 In some cities the specific wording “purpose built” is included in the definition of a WAV, effectively restricting the use of vehicles converted post production, although many coach built vehicles, such as the Allied Vehicles E7, a coach built taxi using a Peugeot chassis, are widely applied as purpose built WAV taxis.

4.9 Authorities were asked to define their approach to accessible taxi policy. Three large cities, Glasgow, Edinburgh and Aberdeen all reported that an accessible taxi policy was in place. In the case of Aberdeen the policy had only recently been adopted and was being introduced in two stages, the first being immediate application to new vehicles, and over time to the existing fleet. Renfrewshire reported a policy that Multi-Purpose Vehicles (MPVs) operating as PHCs would also need to be accessible.

4.10 Aberdeen City Council stated that they had adopted their policy in light of the Equality Act 2010, with reference to sections 149 (public sector equality duty); 158 (positive action); and 165 – 167 (passengers in wheelchairs).

4.11 Councils with a large urban area, particularly those bordering or close to large cities, such as Renfrewshire, were more likely to require accessible taxi use. Smaller cities were split evenly between those with a requirement for accessible taxis, and those with a policy that required some of their fleet to be accessible.

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4.12 The majority of rural communities and councils covering large rural areas did not require taxis to be accessible, but did not discourage their use. In most instances a proportion of the fleet comprised WAV taxis.

4.13 Comments were made by two authorities regarding the lack of national guidance as to what constituted a WAV. One council in particular highlighted that it was waiting for an official statement of vehicle minimum standards from the Scottish Government or UK Department for Transport before requiring operators to go to the expense of purchasing WAVs.

4.14 Vehicle design and capacity to carry wheelchairs are underlined by differences in the design standards permitted across authorities. Differences include the method by which a wheelchair is loaded, side loading being required in Edinburgh, while side and rear loading were more common in other authority areas, including Glasgow. Ease of access was also affected by design minima for door width opening, including the use of a reference manual wheelchair in design specification appropriate for many but not all wheelchair users.

4.15 Differences were also identified in the policies as applied to the taxi and PHC fleets. One authority, Renfrewshire, applied a partial accessibility requirement for larger PHC vehicles, but none required it for all their PHCs. A further issue, that of training and exemptions, arose, with a number of authorities granting exemptions to drivers of WAV taxis from the requirement to carry wheelchairs. Differences in accessibility training also existed between authorities and between the taxi and PHC fleets within authorities, as detailed in the next section.

Training

4.16 The availability and requirement for training was also identified as a key element in service delivery. Respondents were asked to identify the extent to which training was required of the taxi fleet, and of the PHC fleet. Specific areas were identified as:

Geographical Knowledge, Customer Care (General), Equality and Diversity Awareness, Disability Awareness, Licensing conditions, and Safety and reporting procedures

4.17 A significant split emerged between training and knowledge required of taxi

fleets when compared with those of the PHC fleet, with a significantly higher level of training required of the taxi than of the PHC operator.

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4.18 Geographical knowledge training was required of the taxi fleet in approximately 41% of respondents, with a significantly lower number of PHCs (17%). Knowledge of the geography and particularly of street names and routing has played a significant role in taxi training over decades. The London “Knowledge” provides an example of the detail to which such training may be applied. The emergence of route guidance technologies does play a role in this, however, potentially reducing the need for a driver to be able to memorise street names and routes. Rural communities were less likely to require geographical knowledge of taxis than cities, with the exception of Comhairle nan Eilean Siar and the Highland council who both reported the need for geographical knowledge. Glasgow, Edinburgh and Aberdeen all reported the requirement for taxi drivers to attain geographical knowledge training.

4.19 A view was highlighted by a rural council that larger rural councils posed challenges to a geographic test, with many drivers using satellite systems. The same authority commented on a backlash from drivers, experienced when seeking to introduce training requirements in the past.

4.20 Customer care was seen as an appropriate requirement by 25% of authorities, and with a slight bias toward taxi fleets. A smaller number of authorities (10%) identified equality and diversity awareness as appropriate, though this requirement was evenly split between taxi and PHC fleets.

4.21 Disability awareness was seen as appropriate to training in 27% of authority areas, with an even number of authorities requiring disability training of taxis as of PHC fleets. Awareness of licensing conditions and safety were also highly scored, with a bias toward taxis over PHCs (see chart 3, above).

4.22 A number of authorities highlighted the need for a more coordinated approach to the definitions and requirements for training. Most felt that training provided an appropriate minimum standard, with some indicating a need for a national scheme for Scotland would be helpful. Such as scheme would include a basic training minimum standard which would contribute, it was suggested, to the level of service offered by taxi and PHC drivers.

Trade Structure and Representation

4.23 The study sought to identify the relationships between the trade and authorities across Scotland. This included the nature of the trade, its structure and representation, and the methods by which authorities developed policies in discussion with the trade and the public. Authorities were asked to identify the nature of taxi operations in their area, and the extent to which differing operating types were represented. Categories allowed for independent

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operation, without grouping; groups representing taxis and PHCs, and groups representing taxis or PHCs separately. The categories used were:

Independent street taxis (without radio rings) Independent radio rings with taxis and PHCs Taxi Owners' Associations with radio ring Taxi Owners' Associations without radio rings Dispatch companies with PHCs only Dispatch companies with taxis only

4.24 Independent taxis operate without membership of a radio circuit or company. In an urban environment this would require a dependence on street pick ups through hailing and use of ranks, giving rise to the term “street taxi” in many cities. Independent operation in a rural environment reflects differing practices, by contrast, with a larger number of sole traders operating on a stand-alone basis. Rural communities are also less likely to operate taxi ranks or have a significant hailed trade outside larger towns and conurbations.

4.25 Of the operating patterns indicated by responding authorities, 37% of taxis and PHCs operate independently of a central company or radio circuit. This figure falls to 33% of city based taxis operating independently, though some disparity exists between the largest cities. A far smaller number of taxis are reported to operate independently in Edinburgh (25%) than their equivalent in Glasgow (just under 50%). The difference is partially explained by the presence of a number of radio companies in Edinburgh compared to one in Glasgow.

4.26 Independent mixed radio rings with taxi and PHCs accounted for 37% of the Scottish market, though this fell significantly to 18% in larger cities, reflecting the distinct difference between taxis and PHCs in these markets. Taxi owners' associations (9%) and Company based dispatches of taxis only (27%) represented a small part of the total taxi market, but a more significant role in cities (42%), with a very high proportion of the Glasgow market (75% of all taxis).

4.27 In addition to operators and companies, a number of authorities recognised taxi trade and trade union groups. This included Taxi Owners' associations, the union Unite, and expert reference groups, the latter comprising differing trade and stakeholder participants.

4.28 Representation of the trade differed quite significantly between authorities communicating directly with the operators and companies, and those seeking a wider input. Patterns included the operation of general forum, working group meetings and meetings arising from specific issues. A number of locations

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recognised the union Unite as a representative body, though this was not seen as universal. Larger authorities tended to convene meetings with representative groups on a regular basis, though the frequency altered between locations (Glasgow and Renfrewshire every quarter, Aberdeen City, every six months), with additional meetings convened in response to specific issues. Other locations convened meetings on an ad-hoc basis. A smaller number, notably where operators are mainly independent, consulted as they felt appropriate, including consultation via letter (Dumfries and Galloway; East Lothian and Comhairle nan Eilean Siar).

4.29 A number of authorities highlighted that differences of opinion were often expressed at regular meetings, with little agreement between different parts of the trade. This was felt to add to the complexity of decision making.

4.30 The opinion of the public specific to taxi services was included directly in a number of authorities, through surveys and public participation, as well as through the committee process in all areas. Aberdeen City Council included taxi matters as part of a city voice survey, as well as including stakeholders, such as disability and older peoples representatives on their advisory panels. A small number of authorities reported direct public involvement, but the majority did not have a direct input, relying rather on objections to specific actions and a recognised complaints process.

Issuing, refusing and withdrawing licences

4.31 Authorities play a significant role in issuing licences for taxi and PHC fleets. Licences can be issued to drivers, vehicles and booking offices. Taxi licences are typically limited to the geographic boundaries of the issuing authority, though travel with either an origin or a destination beyond the boundary is allowed. Local licensing allows for a specific set of conditions to be applied, most often the standards of vehicles permitted in an area. Thus the licensing conditions may differ between neighbouring authority areas reflecting the differing operating conditions in each. A requirement to ensure public safety and crime prevention for Booking Offices was introduced in 2009.

4.32 Most authorities defined similar minimum requirements in their application processes for driver and vehicle licences. This typically required completed application form, fees and certificates of insurance, roadworthiness and registration in the case of vehicle licences. A number of authorities required vehicle inspection in their facilities prior to issuing a licence.

4.33 Most authorities also made reference to a Scottish Criminal Records Office (SCRO) check prior to granting a licence, effectively a condition under the Fit and Proper Person requirement of the Civic Government (Scotland) Act 1982.

18

A slight difference was noted between authorities taking a pro-active stance requiring SCRO certification, with other reporting a reactive stance where objections were passed to them by the police. Authorities did not indicate any specific methodology for provision of Criminal Record Check certification. A number defined a time period for the receipt of objections from the police. Both Dumfries and Galloway, and Argyll and Bute report a 28 day period within which a response would be required from the police.

4.34 A number of authorities made reference to the need to undertake a medical check, including Aberdeen City Council and East Lothian, as an integral part of their licensing requirements.

4.35 Differences in application process between taxi and PHC licence applications were concentrated on the existence of a licence cap in some authority areas, with additional vehicle quality and taximeter requirements described by some. Age limits also differed between location and by vehicle type, with some authorities citing this as a check required at initial licence issue and renewal.

4.36 Licence applications would be refused across all authorities, if an applicant was not a “Fit and Proper Person”, with across some if there were additional grounds, including:

Failure to respond to requests for information Not presenting a vehicle for inspections Taxi Licence limit reached Objection from the police Objections from medical report

4.37 Authorities may also seek to remove or not renew licences under Section 11

and paragraphs 10-12 of schedule 1 of the Civic Government (Scotland) Act 1982. Immediate suspension would follow under a number of circumstances reported, including:

Complaint from the Chief Constable Serious fault in vehicle Refusal to provide safety equipment, eg: Fire Extinguisher Refusal to provide required operational equipment, eg: Roof top sign Where an owner driver commits a serious offence endangering the public

4.38 Some authorities would seek a suspension rather than withdrawing a licence

entirely in the case of a vehicle defect until such time as the defect was remedied and the vehicle tested. A number also referred to a “warning system”, though in each of these cases the warning system had been superseded by a suspension and retest.

19

4.39 Section 5(3) of the Civic Government (Scotland) Act 1982 allows a Licensing authority to refuse to renew a taxi or PHC licence. A number of authorities illustrated circumstances in which they would not renew a licence including:

Failure to take a vehicle for inspection, Failure to apply in a timely manner Provision of new information from the police regarding suitability Failure to satisfy vehicle age and condition requirements Failure to satisfy medical conditions to drive

4.40 Some respondents highlighted transferability of licences as an issue. Current

legislation does not permit the transfer of licences between individuals, though a number of responses suggested that a demand for licence transfer existed. Larger cities reported that they had received a number of applications in each year to add and remove partners/directors from companies holding licences, effectively a method of transferring licences by changing corporate ownership. Other authorities applied a stricter interpretation underlining that licence transfer was not permissible. A number stated their practice of accepting surrender and re-issue of licences, itself raising the question of prioritisation between applicants where licences were made available in a closed market.

4.41 A further method of “allocating” plates was identified by one authority in which licence owners sought to manage plates or permit the management of their plates by others. The same authority voiced the concern that the current legislation does not adequately permit or exclude such practices, plate management, or equally the ownership of holding companies as described more widely. The result is that the police might not know who is operating a licence, as the person to whom the licence was issued may not be the person involved in the day to day operation of the vehicle.

4.42 One authority described a defined process in relation to the transfer of business ownership, including the Licensing authority consulting the Chief Constable prior to a determination being made.

4.43 The desirability of a method of formal licence transfer was discussed by some respondents, with the majority feeling, where a feeling was expressed, that clarity in law would be preferable to the status quo. Problems arising from the current system were identified by a number of authorities, particularly in locations with a closed market, which might work against the public interest. The development of a standard approach with clarity in law would “create greater consistency of application of the law across the country and allow appropriate modern controls over the taxi services market”.

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5 REVIEW 5.1 The market for taxi services in Scotland appears dynamic and responsive to

customer demand, with a broadly consistent range of controls arising from the Civic Government (Scotland) Act 1982 (the 1982 Act), and applied at local authority level by licensing authorities as the taxi regulators. The range of regulations applied differs between licensing authorities broadly reflecting the local circumstances apparent in each location, as each seeks to maximise the levels of services and benefits available to the travelling public.

5.2 All the authorities responding to the TRI survey indicated that they operated a dual system of taxi licensing, broadly split between taxis able to pick up on street, at rank and by pre-booking; and Private Hire Cars (PHC) limited to pre-booking only. This finding is in line with the Scottish Transport Statistical bulletin, No 30, T1.4 “Taxi Private Hire Cars and drivers licensed by local authorities”, which indicates a similar split across all 32 Scottish authority areas. Nevertheless, a number of differences were noted between authorities, including the extent to which taxis were required to be accessible, the requirements for training and knowledge testing, and approaches to engaging with the industry and the travelling public.

5.3 The choice to restrict numbers appears relatively clear-cut between urban authorities, the majority of whom apply a restriction, and rural locations, the majority of whom do not. Authorities choosing to restrict the numbers of vehicles within their fleets are required, under the 1982 Act, to undertake a survey of their market, most commonly a measurement of Significant Unmet Demand. The act does not define the exact nature of the analysis, although a range of guidance has emerged, with a variety of methodologies applied to date.

5.4 A variety of approaches is noted in respect to the provision of Wheelchair Accessible Vehicles (WAV). Current legislation allows for, but does not require, the stipulation of WAV use in the taxi fleet. Whilst a number of authorities require their use in taxis, no authority applies the same requirement of their PHC fleet. One authority requires larger PHCs to be accessible.

5.5 Wheelchair Accessible Vehicles provide a significant opportunity to provide inclusive transport across many passenger types. Vehicle designs differ, as do the defined vehicles that may operate as WAVs, but all provide for the carriage of passenger in wheelchair without the need either for the passenger to dismount or to collapse the wheelchair. Detailed reviews of accessibility

21

requirements have been undertaken for the UK Government (DfT 200411), and in reviews undertaken by Scottish Licensing authorities (See: Dundee, 201212).

5.6 Vehicle conditions applied in Scotland, including the definitions as to what constitutes a Wheelchair Accessible Vehicle, tend to differ between locations, the majority adopting a list approach of vehicles considered to be accessible; Vehicle type lists are more common than a vehicle design specification, and are argued by some authorities to be more transparent and visible a measure. Two authorities highlight the issue of WAV definition as a concern, suggesting that their adoption of a WAV policy is being delayed by the lack of a national standard. The authorities noting the increased cost of a WAV in comparison with saloon type vehicles, and that a standard vehicle definition would reduce the potential for operators to purchase vehicles that were later proscribed in law.

5.7 The choice between side and rear loading was also identified as an issue, and has received scrutiny at the UK level and some press attention13. Evidence was presented to the UK Parliamentary Select Committee on Transport (December 2010) suggesting that safety may be compromised when using rear-loading vehicles, with similar debates identified in a number of authority areas across England and Wales. Nonetheless, the majority of Scottish Councils did not preclude the use of rear loading wheelchair taxis.

5.8 Some authorities reported the use of an exemption for drivers from duties under the Equality Act, creating a conflict between issuing new licences for WAV taxis, to drivers unable to perform the duties of assisting a wheelchair user. Section 166 of the Equality Act allows licensing authorities to exempt drivers from duties to assist passengers in wheelchairs if they are satisfied that it is appropriate to do so on medical grounds or because the driver’s physical condition makes it impossible or unreasonably difficult for him or her to comply with the duties14. The impact of the exemption may include an effective reduction in the numbers of vehicles available for the carriage of wheelchairs, or a lack of transparency as to vehicle type and availability.

11 Department of Transport, 2004: the determination of accessible taxi requirements. PPA D9/72/87 (UG 539). Available from:http://assets.dft.gov.uk/publications/topics/access-19/ssibletaxirequirementsph6152.pdf, accessed 23rd November 2012 12 http://www.dundeecity.gov.uk/licensing/taxisurvey/, accessed 23rd November 2012 13 UK Parliamentary transport committee, written evidence: taxes and private hire vehicles, the roads reform. House of Commons January 11, 2011. Available at: http://www.publications.parliament.uk/pa/cm201012/cmselect/cmtran/720/720vw01.htm, accessed 23rd November 2012 14 http://www.tfl.gov.uk/assets/downloads/03-11-important-information-regarding-the-introduction-of-the-equality-act-2010.pdf, accessed 23rd November 2012

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Licensing Policies and Policy Engagement

5.9 A significant level of agreement was identified in the survey in respect of the policies in granting, renewing and revoking licences. All authorities sought to apply definitions of “Fit and Proper Persons”, with most involving police checks, Scottish Criminal Records Office Checks, and objections to be taken into account in granting licences.

5.10 Minimum requirements covered the presentation of appropriate documentation, fees and vehicle testing certificates, while some authorities extended this process to include medical checks for applicants for driving licences. The processes differ slightly between locations, with major differences including the agency nominated to undertake vehicle checks, which range from a local agency to the involvement of the police through a public carriage office. Differences also existed between the lengths of time a licence remained valid from first application to renewal, and the frequency of vehicle checks.

5.11 The existence of a range of testing regimes and testing frequencies may reflect a difference in the standards applied between authorities, potentially creating differing levels of vehicle safety, though none of the respondents felt that the testing regime in their area had resulted in dangerous vehicles being allowed into service.

5.12 Local Licensing allowed for the application of local standards, of vehicle type, with differing frequencies reflecting the perceived need to ensure operational standards within the local fleet. This also reflected the allowance, in some authority areas, for a later vehicle retirement. One Licensing authority reported electronic access to its licensing, allowing renewal to be undertaken on-line.

5.13 Processes for involving both the trade and public in policy development varied significantly between locations. Proactive approaches including the constitution and meeting of expert panels, including a wide range of users and operator representatives, though the extent and breadth of such panels may in itself contribute to a level of disagreement within the forum. A number of authorities reported that the frequency at which expert panels were held had created difficulties in resourcing, with one moving from quarterly to twice annually. Other authorities reported an ad-hoc approach to the calling of panels, reflecting actual policy development rather than an on-going forum. A small number of authorities wrote to operators and licence holders as the basis for involvement, suggesting that a physical forum is not the only, and may not be the most appropriate, method of engagement.

5.14 The extent to which taxi forums appear appropriate is most likely to reflect specific policy development, or major issues affecting the delivery of services.

23

Nevertheless, the presence of a common and repeated meeting allows for the presentation and discussion of issues arising in the supply and use of taxis that might not otherwise be considered or known about. Locations with a regular meeting convened on a quarterly or similarly frequent basis reported difficulty in resourcing these meetings. It is equally possible that repetitive meetings may lose focus or interest where new issues are not identified. A further issue is alluded to in some authorities, that attendance at the meetings may not be fully representative.

5.15 Representative groups, including those of public interest, such as disability action groups, groups representing particular sectors of the population, and other stakeholders do remain relevant to the development of taxi policy. Localised forum and engagement ensures that the issues presented remain relevant and in the interest of the group.

Training for Taxi Drivers

5.16 Significant differences existed between licensing authorities in terms of the training requirements, though all recognised the significance of training to their fleets. Training requirements were generally less onerous for PHC drivers, although some was required. The range of training requirements also differed between locations, with larger cities more likely to apply a comprehensive set of requirements than rural authorities. Differences also existed in the perceived reaction of the trade to a training requirement, with one authority reporting a view that the taxi trade had reacted negatively to a previous attempt by the authority to require training. The survey identified differing areas in which training may be offered, seeking to identify the application of each by area and fleet type.

5.17 41% of authorities responding to the survey required geographical knowledge training of their taxi fleets, with a significantly lower proportion, under 20%, applying the same standard to their PHC fleets. A distinct difference emerged between location types, with Urban authorities more likely to require a geographical knowledge than rural communities. It was noted that one rural authority suggested that the larger area of a rural authority, as opposed to an urban one, would make a geographical knowledge requirement more onerous to their drivers. The same authority argued that current mobile navigation equipment was a more accurate method of ensuring correct destination selection and routing.

5.18 The role of mobile technologies was cited in a number of responses, and the development of navigation systems based on the use of Satellite Locating

24

algorithms, principally based on GPS, has become ubiquitous in a number of applications.

5.19 The second area of training identified related to Customer Care. An even smaller number of authorities identified customer care as an area requiring specific knowledge compared to geographical knowledge. 25% of respondents required taxi drivers to complete customer care training, with a slightly lower number of PHC drivers required to undertake the same training. The absence of a specific Customer Care element may impact on the perception of taxi services, though some authorities noted the role of taxi operators and companies in providing support to their passengers.

5.20 Equality and diversity training, the awareness of differing and diverse groups, appeared the least frequently of any training area, with less than 10% of authorities requiring training or awareness in this area.

5.21 Disability awareness was identified in the survey as appropriate to taxis and PHCs in equal number by 30% of respondents. The number of authorities requiring any form of disability awareness falls below the number requiring accessibility in taxi fleets. This might, in turn, raise a question as to the effectiveness of accessible vehicle provision. A similar correlation may be suggested between WAV requirement and the issuing of exemptions to drivers from providing loading assistance to wheelchair users.

5.22 Disability awareness provides, ideally, an understanding by the driver of the needs and sensitivities of passengers with disabilities. A dichotomy arises from the range of passengers with some additional access needs, and the common concentration of vehicle type on those with wheelchairs, which require specific and purpose built vehicle design and fittings to carry passengers in wheelchairs. Needs of passengers differ, as do the appropriate levels of assistance, with a variety of needs covered by disability awareness training courses. Good practice was identified in a number of authority areas, including Perth and Kinross, where training was undertaken voluntarily by some drivers. Training addressed a range of impairments including sight, hearing and cognitive requirements, as well as appropriate handling of wheelchairs in taxi use.

5.23 An awareness of the licensing requirements of an authority and safety training were also highlighted as significant, with a majority of authorities expecting a knowledge of the licensing requirements of their taxi drivers. A larger number of authorities expected awareness of licensing of its taxis than of its PHCs, which is likely to reflect the relationship between taxi drivers and PHC companies with their respective authorities. Safety training ranked the second

25

highest area in which training was required, with a similar bias toward training of taxi fleet drivers over PHC fleets.

Licence Transferability

5.24 The extent to which a licence may be transferred was identified as an issue in some authority responses. Most responses indicated that the vehicle licence was not transferable within the meanings of the Civic Government (Scotland) Act, but a number identified methods by which a licence might currently change hands, the majority of which indicated that changes in company ownership would result in a de facto change in the ownership of a licence.

5.25 A number of authorities highlighted the need for consistency and the desire for guidelines to clarify appropriate responses to licence transferability. Responses split between locations which indicated that no transfer was permitted, nor allowed, and locations which identified the demand for transferability and changes in corporate ownership that may result de facto in the exchange of licence ownership. In this respect, the potential for differences in approach between authorities could be suggested to confuse and provide evidential support to two opposing approaches.

6 CONCLUSIONS 6.1 The delivery of taxi and PHC services in Scotland follows a series of distinct

operating patterns permitted and guided by the Civic Government (Scotland) Act 1982. Services are broadly split in to one of two tiers, taxis able to ply for hire and respond to pre-bookings, and Private Hire Cars (PHCs) that may legally respond to pre-booking only, giving rise to the term two-tier system. All authorities permit both types of vehicles, whilst some require taxis to be operated by Wheelchair Accessible Vehicles (WAV). The exact definition of WAV differs between authorities reflecting the lack of a single standard definition as to what can be defined as a WAV.

6.2 Authorities also follow similar patterns in the issue of licence and the requirements required for taxi licensing. The vast majority of authorities chose to license drivers and vehicles separately, with licence validity varying slightly between locations. A small variation exists between the lifespan of a licence, typically valid between one and three years.

6.3 Processes for obtaining a licence also appear mainly consistent, and all quote the governing Civic Government Act. Licences are issued where a holder is

26

considered a “fit and proper person”, though some differences exist in the extent to which police objections are considered. The primary difference being between authorities that take a pro-active stance, and authorities which are reactive.

6.4 Transferability of licences was also included in the survey. Under current regulation, the Civic Government (Scotland) Act, the transfer of licences between individuals is not permitted. This may underestimate, however, both the desire to transfer and range of methods currently used to change ownership. Licences were noted to have a market value in some areas, with some concern related to the impact of changes to market structure. A split emerged in responses between authorities not permitting any form of transfer, and those that permitted the change of ownership within a corporate buy-out.

6.5 The extent to which licences may be transferred, and in what circumstances, is highlighted by the stated desire for clarity and consistency in a number of responses, suggesting benefit from a clear statement of policy at a national level.

6.6 The work also considered the extent to which training was supplied in the Scottish taxi market. A difference was highlighted in the extent to which taxis and PHCs differed, with a stricter regime applied to taxis. A number of authorities required a wide range of training, though an apparent mismatch appeared between those requiring the provision of WAVs and those requiring training in disability awareness. Customer Care also appeared to be a low priority in a number of authorities.

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7 APPENDICES Appendix 1: Survey Document

Page 1

Scottish Government taxi surveyScottish Government taxi surveyScottish Government taxi surveyScottish Government taxi survey

The  Taxi  Research  Group  at  Edinburgh  Napier  University  has  been  asked  to  undertake  a  survey  of  Scottish  licensing  authorities  on  behalf  of  the  Scottish  Government  to  inform  the  development  of  understanding  and  national  policies  related  to  taxi  and  private  hire  car  licensing.  I  am  writing  to  all  licensing  authorities  in  Scotland  asking  that  you  help  us  with  a  few  minutes  of  your  time  in  completing  this  on  line  survey  for  us.      Information  provided  in  this  survey  will  be  used  to  create  a  report  for  the  Scottish  Government  providing  a  snapshot  of  the  taxi  and  private  hire  car  markets  and  licensing  regimes  across  Scotland.    If  you  have  any  questions  regarding  the  purpose  of  the  research,  please  contact  Joanna  Mackenzie  of  the  Scottish  Government  Licensing  Team  (Joanna.Mackenzie2@scotland.gsi.gov.uk,  0131  244  8242).  For  questions  on  the  format  or  methodology  of  the  research  please  contact  me  at  j.cooper@napier.ac.uk,  0131  208  1055.        Sincerely  James  Cooper,  Head  of  Taxi  Studies  

1. Name of authority

 

2. Is your authority:

3. Who can we contact if we have a question regarding your licensing policy. Please

include a name, telephone or email details.

 

4. How long does a licence last from issue or renewal to next renewal

5. Do you operate an accessible vehicle policy, or are planning to introduce one? If so,

could you briefly describe this policy.

 

 

 About taxi licensing in your authority

Years

City  Authority,  with  exclusively  urban  area  

City  and  suburbs,  urban  and  suburban  

Mixed,  mainly  urban  

Mixed,  equal  split  between  urban  and  rural  

Mainly  rural  

Other  (please  specify)  

28

Page 2

Scottish Government taxi surveyScottish Government taxi surveyScottish Government taxi surveyScottish Government taxi survey6. What processes / documentation do you require on initial application and renewal of

a taxi licence and a private hire car licence. Please indicate the nature and extent of

police involvement in this process.

 

7. Please outline the main differences between applications for a taxi and for a private

hire car licence

 

8. In what circumstances would you refuse to issue a new taxi licence or private hire car

licence?

 

9. In what circumstances would you immediately suspend or withdraw a taxi licence or

a private hire car licence? If you operate a warning system leading to suspension

please describe this as well.

 

10. In what circumstances would you not renew a taxi licence or a private hire car

licence?

 

11. Please tell us about the general operating patterns in your area. Please include a

brief description of the organisation of the trade, arrangements for discussion between

the trade and yourselves, points of agreement with the trade, areas where differences in

views have been expressed.

 

 Operating practices

29

Page 3

Scottish Government taxi surveyScottish Government taxi surveyScottish Government taxi surveyScottish Government taxi survey12. Please indicate whether the following groups exist in your area, and the extent you

feel they represent the taxi trade. Please indicate all groups, including multiple

memberships (ie: totals can exceed 100%)

13. Please could you indicate the types of vehicles you licence for taxi use, and for

private hire car use. Please use the additional information box to detail specific design

requirements. Please tick in all appropriate boxes.

14. Do you have separate licences for taxis and private hire cars?

15. Do you have separate licences for taxi and private hire car drivers?

None  --  0%Minority  --  upto  

about  25%Small  Minority  --  

25  --  50%Small  Majority  --  

50  --  75%Majority  --  over  

75%Entirety  of  trade  --  

100%

Independent  street  taxis  (outwith  radio  rings)

Independent  Radio  rings  with  taxis  and  private  hire  cars

Taxi  Owners  association  with  radio  ring

Taxi  Owners  association  without  radio  ring

Dispatch  companies  with  private  hire  cars  alone

Dispatch  companies  with  taxis  alone

Hatchback  type  vehicle  3  

doors

Hatchback  type  vehicle  5  

doors

Saloon  type  vehicle  2  

doors

Saloon  type  vehicle  4  

doors

Purpose  built  Wheelchair  accessible  vehicle  5  

seats

Purpose  built  Wheelchair  accessible  vehicle  6  

seats

Accessible  van  up  to  8  

seats

Non--accessible  

van  up  to  8  seats

Taxi  Use

Private  Hire  Car  Use

Additional  information  

Yes  

No  

Yes  

No  

30

Page 4

Scottish Government taxi surveyScottish Government taxi surveyScottish Government taxi surveyScottish Government taxi survey16. This question asks about training programmes required or felt desirable for your

fleet. For each option please indicate whether training is required and the nature of

training provided. Please use the comment box for any further information you feel

appropriate.

17. Do you require private hire cars to be fitted with meters. If yes, please could

describe the extent to which PHCs are required to use the same maximum fares applied

to Taxis, and how you callibrate PHC meters.

18. This question considers transferability of taxi licenses. Are licenses in your

authority transferable, and to what extent (eg. Between members of the same family, on

the open market, by purchase of companies etc.). Does transfer of licenses cause an

issue in your authority?

 

19. Are you aware of your local market? Do you assess who uses taxis and private hire

cars?

 

Required  of  taxi  drivers

Recommended  but  not  required  of  

taxi  drivers

Not  required  of  taxi  drivers

Required  of  private  hire  car  

drivers

Recommended  but  not  required  of  

private  hire  car  drivers

Not  required  of  private  hire  car  

drivers

Geographical  knowledge

Customer  Care  (general)

Equality  and  diversity  awareness

Disability  Awareness

Licensing  conditions

Safety  and  reporting  procedures

Further  information  

Yes  

No  

In  some  instances  (describe  below)  

Further  information  

31

Page 5

Scottish Government taxi surveyScottish Government taxi surveyScottish Government taxi surveyScottish Government taxi survey20. Do you have a recognised group, or number of groups that present user views to

you in respect of taxis and private hire cars. Please list all of the groups you recognise

or have a role in forwarding comments and complaints to you?

 

21. Please use the box below for any additional comments. If you want to provide

further information or comments you feel appropriate at a later stage, please address

these to j.cooper@napier.ac.uk

 

32

Appendix 2: Survey Responses

All authorities responding to the survey distinguish between taxis and PHCs Chart 1: In what Area does your authority operate?

Chart 2: How long does a licence last from issue to next renewal?

33

Chart 3: Please indicate whether the following groups exist in you area:

Chart 4: Please indicate the types of vehicles you license for taxi use and for private hire care use.

34

Chart 5: Do you have separate licences for taxis and private hire cars?

Chart 6: Do you have a separate licence for taxi and private hire car drivers?

35

Chart 7: This question asks about training programmes required or felt desirable for your fleet.

Chart 8: Do you require private hire cars to be fitted with meters?

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